DRAFT
FACILITIES STORING HAZARDOUS WASTE IN CONTAINERS
A Technical Resource Document for- Permit Writers
This document (SW-XXX) was prepared by Fred C. Hart, Inc.,
under contract to EPA's Office of Solid Waste, and Karen A. Walker
of the Hazardous and Industrial Waste Division, Office of Solid
Waste.
This document has not been peer and administratively
reviewed within EPA and is for internal Agency use/
distribution only.
U.S. ENVIRONMENTAL PROTECTION AGENCY/1982
-------
PREFACE
This is one of a series of technical resource documents that
provides information on standards for facilities that treat, store,
or dispose of hazardous waste.
The documents are being developed to assist permit writers in
evaluating facilities against standards (40 Code of Federal Regu-
1 at t ions, Part 264) issued under Subtitle C of the Resource Conserva-
tion and Recovery Act (RCRA) of 1976, as amended. Included"in these
documents is detailed information about design, equipment, and
specific procedures for evaluating data submitted by the permit
applicant, as well as bibliographies that can be used to locate
additional information.
The series, which is being produced by the Technology Branch
of EPA's Office of Solid Waste, includes guidance on:
0 containers
0 tanks
8 compatibility of wastes
incineration
Permit writers should keep in mind when using this material
that the regulations are subject to change through amendments
and modifications and should incorporate any changes into their
evaluations of facilities.
The "material contained herein i.s; for guidance purposes only
and' is. nof enforceable;'' The technical'resoarce documents; are not
tp-be interpreted as'amending the'facility standards in .40 C.FR
Part:264."
ii
-------
CONTENTS
Page
INTRODUCTION 1-1
QUESTIONS TO BE CONSIDERED BY THE PERiMIT WRITER 2-1
Checklist for Permit Writers 2-1
Questions to Be Answered
by the Permit Writer
TYPES OF .CONTAINERS 3-1
Steel Containers 3-2
Plastic Containers 3-16
Fiber Containers 3-16
Barrels and Kegs 3-20
Bags and Sacks 3-21
Carboys 3-23
Containers for Storing Ignitable
and Combustible Liquids 3-24
MANAGEMENT OF CONTAINERS 4-1
Introduction 4-1
Current Storage Practices 4-1
Condition of Containers 4-8
Compatibility of Waste with
Containers 4—11
Incompatible Wastes 4-11
Storage of Ignitable
or Reactive Waste 4-12
Containment 4-12
INSPECTION OF CONTAINER FACILITIES 5-1
Containers 5-1
Container Storage Areas and
the Containment System 5-5
Evaluation of an Inspection Plan 5-6
HAZARDOUS WASTE CONTAINER COSTS . 6-1
Introduction 6-1
Container Costs 6-1
Containment System Costs 6-4
REFERENCES 7-1
ill
-------
TABLES
3-1 Types of Containers 3-4
3-2 Properties of Principal Coating Resin 3-9
3-3 Typical Steel-Drum Specifications for
Hazardous Materials 3-13
3-4 Advantages and Disadvantages
of Different Types of Containers 3-15
3-5 Chemical Resistance of Important Plastics 3-17
3-6 Materials and Closures of Fiber Containers 3-19
4-1 Outdoor Liquid Storage in Containers 4-6
5-1 Container Storage Facility
Inspection Points 5-8
6—1 Prices of New Containers 6-2
6-2 Prices of New and Reconditioned
Containers (TABADA survey) 6-3
FIGURES
Automatic Container Palleting 4-4
Types of Corrosion 5-1
IV
-------
INTRODUCTION
This manual provides the permit writer with a systematic
approach to evaluating permit applications from facilities that
store hazardous waste in containers.
Owners and operators of facilities that use containers to
store hazardous waste are regulated under authority of Section 3004
of the Resource Conservation and Recovery Act (RCRA). Regulations
promulgated under RCRA on the use and management of containers
are found in Sections 264.170-264.178, Subpart I, Title 40, of
the Code of Federal Regulations (CFR). The procedural requirements
for obtaining a hazardous waste facility permit are in 40 CFR
122 and 124.
EPA's regulations provide for issuing hazardous waste facility
permits in two phrases: Part A of the permit application (interim
status) and Part 3 of the permit application (permanent status—
the final permit). Interim status allows facilities that are in
existence to continue operations while administrative action on
the final permit is under way. These facilities must submit Part
B of the permit application 180 days prior to beginning physical
construction.
Part B of the permit application requires information on the
equipment, structures, and procedures used for managing hazardous
waste at the facility. The application must also provide data on
the physical and chemical characteristics of the wastes to be handled,
(See 40 CFR §122.25 of the Consolidated Permit Regulations for
the contents of Part B.)
1-1
-------
The permit writer evaluates the information provided in Part
B of the application to determine whether the facility meets the
administrative and technical standards (40 CFR 264) and the
procedural requirements for obtaining a permit (40 CFR 122 and
124). The permit writers' manuals provide background information
and procedures for evaluating the data provided by the applicant.
The administrative procedures permit manual (prepared by EPA's
Office of Enforcement)1 provides information on procedures to
follow from the initial contact with an applicant through review,
public hearing, and any administrative appeals of permit decisions.
The manual also contains guidance for conducting technical reviews.
Various sections of the final regulations for storage reflect
the use of best engineering judgment (BEJ). This concept entails
the. application of case-by-case judgment, based on site-specific
circumstances, in evaluating facilities for issuing permits. In
those sections of the regulations that have been written from a
BEJ standpoint, some flexibility is allowed on the part of the
owner or operator in meeting permit requirements. The Agency
feels that evaluating facilities individually will ensure the
protection of human health and the environment and, at the same
time, avoid overly restrictive requirements that might result
from application of specific uniform rules for all facilities.
BEJ provides for tailoring of permit requirements to the
specific wastes, facility design, and environmental conditions of
the storage area, based on the best engineering judgment of the
permit writer. In order to make these judgments, the permit
1-2
-------
writer must have access to information on current technologies and
the specific site.
The storage regulation for containers requires complete contain-
ment of the waste. No discharge into the land, surface water, or
ground water is permitted. Three lines of defense against potential
discharge are built into the regulation: (1) a primary containment
device (the container itself); (2) regular inspections to verify
condition of containers and to ensure that leaks or other problems
do not go unnoticed; and (3) a secondary containment system
capable of holding any discharges that should occur.
The regulatory definition of "containers" is "any portable
device in which a material is stored, transported, treated, disposed
of, or otherwise handled" (40 CFR Section 260.10). Specific stand-
ards for managing hazardous waste stored in containers are in
Subpart I, 40 CFR S §264.170-177. These standards cover the following
general areas:
condition of containers
compatibility of wastes with container material and of
wastes with wastes
- management of containers
inspections
containment
- special requirements for ignitable or reactive wastes
special requirements for incompatible wastes
closure
1-3
-------
CHAPTER 2
QUESTIONS TO BE CONSIDERED BY THE PERMIT WRITER
These questions will aid permit writers in evaluating
applications of owners or operators of facilities that use con-
tainers for storage of hazardous waste. The first section is a
checklist of questions designed to assess the completeness of
the application. The second section consists of general design
and operating questions-
A. Checklist for Permit Writers
The following outline will assist permit writers in assessing
the completeness and adequacy of a permit application.
1. General Facility Description
.- aumber of containers
- location of containers
- buffer zone for ignitable/reactive
waste in containers (§264.176)
2. Chemical and Physical Analyses of Wastes
- information necessary to determine waste-to-waste
compatibility, waste-to-container compatibility,
and ignitability or reactivity
3. Waste Analysis Plan
— analyses or trial tests used to determine waste-to-
waste and waste-to-container compatibilities
- analyses for determination of ignitability and reactivity
- methods for selecting representative samples
- frequency with which-original analysis will be reviewed
or repeated
- source of other information on composition and
2-1
-------
characteristics of waste for off-site facilities
- inspection of shipments received at the facility
4.- Description of Security
5. Inspection Schedule
- schedule for inspecting container storage areas and
containment systems, as specified in §264.174
- list of items to be inspected for corrosion or rusting
of containers, cracking of containment base, etc.
6. Justification for Waiver of Preparedness and Prevention
Requirements
7. Contingency Plan
- actions to be taken in response to fires, explosions,
or unplanned releases of hazardous waste
— arrangements with police department, fire department,
hospitals, contractors, and State and local emergency
response teams
- list o£ emergency coordiriators
- list and location of emergency equipment
- evacuation plan, if necessary
8* Description of Procedures to:
- prevent hazards in unloading
- prevent runoff from handling areas
- prevent contamination of water supplies
- mitigate effects of equipment failure and power outages
- prevent exposure of personnel to hazardous waste
9. Description of Precautions to Prevent Accidental Ignition
or Reaction
- precautions to prevent ignition or reaction -of
ignitable, reactive, or incompatible waste
- documentation demonstrating compliance with §264.17(a)
(see item 20 of this checklist)
2-2
-------
10. Traffic Pattern and Volume
11. Facility Location
- political jurisdiction in which facility lies
- if facility is in an area listed in Appendix VI. of
Part 264, demonstration of compliance with the seismic
standard (see §§264.18 and 122.25(a) (11) (ii) for details)
- identification of whether facility is located in 100-
year floodplain
- if facility is in a 100-year floodplain, engineering
analyses showing design of operational units and
flood-protection devices and their ability to withstand
forces of a 100-year flood, or procedures for removing
hazardous waste prior to a flood (see §§264.18(b) and
122..25(a) (11) (lv) for details)
- if existing facility is not in compliance with
§264.13(b), a plan and schedule for bringing facility
into compliance
12. Outline of Training Program
13. Closure Plan (see §264.112 for details)
!£•. Closure Cost Estimate and Financial Assurance Mechanism
(see §§264.142 and 264.143 for details)
15. Documentation of Compliance with §264.147, Liability
Requirements, if Applicable
16. Proof of Coverage by State Financial Mechanism, Where
Appropriate (see §§264.149 or 264.150)
17. Topographic Map (see §122.2 5(a) (19) for details)
18. Design Information When a Containment System is Required*
- design parameters, dimensions, and materials of
construction
- how containers will be managed so that they are not
stored in accumulated liquids
* A containment svstem is not required in storage- areas, where
containers hold only wastes that do not contain free liquids, IE
the conditions in 40 CFR 264.175(0 (46 FR 55112, November 6, 1981)
are me t.
2-3
-------
- description of methods to prevent run-on
- capacity of the containment system
- procedures for analyzing and removing accumulated liquids
19. Justification for Waiver of .Containment System Requirements
20. Procedures for Handling Incompatible, Ignitable, or
Reactive Waste
- for offsite facilities, procedures for inspecting
each shipment of waste received at the facility (part
of the waste analysis plan)
- procedures for treating waste prior to placement in
containers, where applicable
- procedures used to prevent a waste from being placed
in an unwashed tank, that previously held an incompatible
waste
— procedures used to prevent incompatible wastes from
being placed in the sane container
- documentation of compliance with buffer zone requirement
B. Questions to Be Answered by the Permit Writer
The following questions can be used by the permit writer
in evaluating the information in the permit application and in
preparing a facility permit. The text of this manual provides
the permit writer with information as to how these questions can
be answered.
1. Type of Container and Condition
Is the vessel portable (i.e., is it a container)?
Is the container in "good condition" (free of leaks,
excessive rusts and dents, corrosion, etc.)?
Is the container marked in accordance with Department
of Transportation (DOT) specifications?
Are there procedures to ensure that should the condition
of a container deteriorate to the point that it can no
longer be used, will its contents be transferred to a
2-4
-------
container that is in good condition (e.g., does the
permit applicant have an adequate supply of empty drums
that can be used in this type of situation, etc.)?
2. Compatibility of Waste with Container
Does the waste analysis plan specify adequate procedures
for determining whether the waste is compatible with the
container construction or lining material?
3. Management of Containers
Are containers handled, in such a way as to ensure that
ruptures, leaks, or other damage do not occur?
Are containers always kept closed except when emptying
and filling?
How are leaking and otherwise damaged containers handled?
Are they discarded or sent to a reconditioner?
4. Inspection
Does the inspection schedule contain the items required
by §264.L74?
Are the inspection procedures adequate to detect .".eaking
and otherwise damaged containers and deterioration of
the containment system components?
5. Containment
Is the containment system, jbase free of cracks and gaps
and sufficiently impervious to hold spilled or leaked
waste or precipitation until it is detected and removed?
Does the design of the containment system provide a
means to prevent containers from prolonged contact with
accumulated waste (e.g., drainage designs, elevation of
the containers on racks or pallets)?
Is the capacity of the system 10 percent of the total
volume of the containers or of the largest container
(whichever is greater)?
Does the design of the containment system include measures
to prevent run-on?
Are plans or procedures for removal of waste from the
containment area adequate to prevent overflow?
2-5
-------
Ignitable, Reactive, and Incompatible Waste
Are containers of ignitable and/or reactive waste located
at least 50 feet from the property line of the facility?
Are procedures for management of incompatible wastes
adequate to satisfy the requirements of §264.177?
Closure
Has waste been charaterized (chemical composition,
physical state, etc-)?
Has maximum inventory at closure been estimated?-
Are expected year of closure and schedule of closure
procedures itemized?
3ow will wastes and residue be removed from the containers?
Will the waste be treated, stored, or disposed of onsite
or offsite?
How will the containment system components be
decontaminated or cleaned? If not possible, does the
plan- specify an option for removal and disposal?
How will contaminated soils, cleaning.products, equipment,
residues, etc-, be disposed of?
2-6
-------
CHAPTER 3
TYPES OF CONTAINERS
At present, there are no containers of which the Agency is
aware that are manufactured specifically for the storage of
hazardous waste, with the exception of those used for high-level
radioactive waste. Therefore, drums made for other purposes have
been adopted for containerizing hazardous waste. Specific designs
appropriate for the contraction of containers for various types
of hazardous waste would-likely be more protective. These would
be developed by analyzing many of the considerations pertinent to
hazardous waste storage (for example, corrosivity, longevity of
storage, etc.). Currently, EPA is reviewing drum design standards
developed by various organizations in an attempt to resolve this
issue. Because no current design standards exist, however,
containers that are commonly used in the storage of hazardous
waste will be discussed in this chapter.
This chapter emphasizes factors relevant to the evaluation
of the appropriateness and effectiveness of each type of container,
Compatibility and corrosion factors for each kind of container
are also highlighted since these components are inseparably linked
to safety and to the prevention of discharge of hazardous wastes.
Steel drums of 55-gallon capacity and plastic containers are
most frequently used to containerize and store hazardous waste.
The useful life of a container is dependent on its resistance to
corrosion and to chemical deterioration. Steel drums, often with
appropriate protective lining or coating material, are suitable
3-1
-------
for the storage of corrosive, reactive, ignitable, or toxic waste.
Plastic containers are also well adapted for holding corrosive
wastes since they are generally resistant to chemicals-
Since compatibility of the waste with the structural material
of the container is important to prevention of failure of the
container, this compatibility must be determined prior to storage.
To ascertain the compatibility of a specific waste with a-specific
container, the following information is needed: (1) characteristics
of the waste, (2) intended use of the container and its structural
characteristics, (3) Length of storage, and (4) storage conditions
(e.g., temperature and humidity). This determination is so
critical that a container that has been specifically designed for
a particular substance may not be suitable for an off-specification
batch of that same substance. Ear example, a chemical compound
contaminated with only a few parts per million (ppm) of chloride
may begin to deteriorate rapidly an unprotected steel container.
For more information on compatibility, see EPA's permit writers
guide on compatibility of hazardous wastes.2
In addition, this chapiter addresses.the advantages and
disadvantages of various containers that may be used for the
storage of hazardous waste. Special considerations for selecting
appropriate containers for the storage of flammable and combustible
wastes are also discussed.
A. Steel Containers
Steel containers vary in capacity from 1- to 12-gallon
metal pails to the standard-size 55-gallon drum. Other standard
3-2
-------
sizes are presented in Table 3-1. This section deals primarily
with the 55-gallon drun because of its overwhelming popularity
in storage.
The metal pail is defined by the U.S. Department of Commerce
as a single-rolled shipping container with a volume of from 1 to
12 gallons. Pails are generally constructed of minimum 28-gauge
mild steel. This gauge is often specified for pails that are
designed to hold dry bulk materials. Standard markings include
the steel gauge, capacity, and date of manufacture. For example,
the marking 28-5-77 denotes a 28-gauge pail of 5-gallon capacity
made in 1977. Pallets should be provided when pails are used to
store hazardous waste.
1. Compatibility and Corrosion
As already mentioned, compatibility of waste with the
container is integral to prevention of discharge of the waste and
subsequent contamination of the environment. Storage conditions
such as humidity, pH, and temperature can significantly affect
the corrosion resistance of a particular container. (See Chapter
4, "Management of Containers," for a further discussion.) when
assessing the suitability of a container for a particular waste,
the permit writer must rely on the best available data.
Steel drums are usually fabricated from mild steel or low-
alloy steels and have a low resistance to corrosion. Noncoated
steel drums are well suited for wastes that are not highly
corrosive such as mild alkaies, mild acids, and nonhalogenated
organics. They are generally not compatible, however, with strong
3-3
-------
TABLE 3-1
Container size, description
j Usable ;
i volume, i
I eu. ft. !
Metal
53 gaL. steel std. IS-gagc plate. DOTM7E, new 7.33
53 gal. steel, std.' 16-$age plate. DOT-17C. new 733
55 gaL. steel, removable head. 18-gage. Rule 40. new v . 7.33
55 gaL. steel removable head, '?„ gage. DOT-17H. new | 7.35 |
55 gaL. steei. removable head, 18 gage. used, reconditioned 7.35
55 gaL. steei. std. 18 gage. used, inspected, cleaned ' . - - "35
55 gaLraluramum. std. 0.102-m. plat* '35
55 gaL. type 304 stainless steei. std. 16 gage. DOT-SC j '35 \
30 gaL, steal, std. 20 gage. DOT-17E .- 4.00 \
30 gaL, steei. removable head, 20-gage, Rule 40 4.00 |
18 gal, steel, removable lug cover. 22 gage • 2J4 I
55 gal. steei-anil galvanized, std. IS gage. DOT-tTE 7.35 j
53 gaL. steel removable head. 40-mil polyethylene liner, external fittings, 20/18 gage.
53-S-gaL unhie volume. DOT-37M "3D
Fiber draaw*
81 gaL. 9 ply. 400-lb. load limit, dry products only. Rule 40 8.1?
55 gaL, 9 ply. 400-lb. load limit, dry products only. Rule 40 7J5 I
47 gaL, 9 ply. 400-lb. load limit, dry products only. Rule 40 9.23
41 gaL, 9 ply. 400-lb. load limit dry products only. Rule 40 5.43
30 gaL. 9 ply. 400-tb. load limit, dry products only. Rule 40 4.00 i
30 gaL. 7 ply. 223-lb. load limit, dry products only. Rule 40 4.00 I
IS gaL. 8 ply. 150-lb. load limit, dry product! only. Rule 40 2.00 j
55 jaL. 9 ply, polyethylene barrier. 400-lb. load limit. Rule 4O 7.35 !
55 gaL. 9 ply. polyethylene-aluminum foil liner. 400-lb. load limit.. Rule 40 735 \
55 gaL. 10 ply, blow-molded 15-mil polyethylene liquid-tight liner, tight head, sted cover j
with 2- and.y«-in. NTT openings. SOO-lb. load limit. DOT-21C21CP liquid products . . . . 7.35 {
30 gaL. 9 ply. same as preceding except 430-lb. load limit 4.00
30 gaL. 8 ply. 300-lb. load limit, removable fiber cover, no barrier 4.00
13 gaL. 8 ply. same u preceding except 150-lb. load limit 2.00
1 gaL. 5 ply. same as preceding except 150-lb. load limit 0.1333
53 gaL. 9 ply, 400-lb. load limit, semisquare removable nber cover. "Rocon" style 7.35
45 gaL. same as. preceding 8X31
Bags, mvitrwaO paper. paivethylesw(fE) Slav
. Pasted-valve bag. 20"t x 22-ia. face. SV.-in. top and bottom with l-iml free Mm. 2/50. 1/60
kraft. plain, no printing. PE internal sleeve ' 1.33
Sawn-valve bag. 15 x 5V, x 301/, in. S'/.-m. PE internal sleeve with 1-nul free Sim. 2/50. j
I/CO- KaUX^ f"MH, ftaT p^^lflltgt r
I
Pasted-valve bag, 18% X 22% in. 3Vfia. top and bottom. PE internal sleeve. 3/50 kraft. j
plain, no prating { 0.84
Sewa open-mouth bag, 20 x 4 x 30*. in. 3/50. 1/80 kraft plain 2.00
Sewn-vmive bag. 19 X 5 X 33% in. 5y,-in. tuck-in sleeve. 3/50. 1/60 kraft. plain iOO
Pasted-valve bag, 24 x 25% m. SVj-in. top and bottom, tuck-in sifcve. 3/50. 1/60 kraft,
plain 2.00
Pasted open-mouth baler bags. 22 x 24 id. 6-in. bottom. 1/130 kraft (or 2/70). plain
Hat-robe, open-mouth bag. 10-mil PE film, plain. 20V. x 34'.', in. 133
Square-end valve bag, 20% x 23-in. face. 5%-in. top and bottom. 10-mil PE Sim, plain 1.33
Small baas, pouches, folding boxet
Poucn, Sf, X 16* in. 2-pty PE film. 2-mil thickness/ply I 0.12
Bag. sugar-pocket style. 6 x 2% X 16V, in. 2- to 40-lb. baas weight, natural kraft paper .1 0.12
Bag. pioca style. 8% x 3 X 21 uu 2- to 40-lb, basis weight, natural kraft : 0.12
Folding box. 5 x 1 X 8 in. ravene-cuck design. 12-pomt krah board with bleached white |
exrenor j (1028
Folding box, 9V, x 4% x 13 in. full overlap top and bottom. 30-point chip board with i
bleached white exterior I 0 3~
Corrucated cartons, bulk bases • 1
Regular slotted carton (RSQ. 24 X 16 x 8 in. 275-lb. test double wall, stapled (stitched)
joint
RSC. 18 x 6 x 24 in. 275-lb. test double walL stitched joint, end-opening style
Bag-in-box, RSC 15 x 15 X 22 in. 275-lb. test double wall, stitched liner. SOO-lb. test.
double wall
Bulk box. 600/900 'test in Ib. for both pieces), laminated inner lining approximately
41 x 34 x 38 in. less PE liner and pallet | 3.00
Carbovs, plastic drams, jars, bottles I
Carboy. 13% gaL. poivethvlene. Wow-molded j 1.35
Drum, polyethylene. 15 gaL, blow-molded. tCC-34 (DOT-341 ] ISO
Carboy. 13 gaL, glass, nitric acid service, wooden crate 2.00
Jug. I f1 glass, with Snger handle, piasnc cap _...-..] 0.1335
Bottle. 1 qc. glass. "Boston" round, plastic cap I 0.034
Jar. 1 qu glass, wide mouth, plastic cap : 0.034
(cant.)
-------
TABLE 3-1
of_ Containers
Connin*r sixe. decription '
Carbo»t, piaidc dram. jus. bo(d« icotAiuurf)
Cam.pwb
WnpoMttriaii
CZndcJ ltd rnrfcacioc* -
FUm. poiy«thyiW. shctiabU 70% tntchio* dirKttock. 30% CIQH ottchiot diractioo.
*imi*i hmfnrm chntita** w V» (Ylfl «n in VMS t/miD I'Tftwfol S-2D31*
Tilra. peiypropylMM; ihnakafalc. yield bcror* liuuikaf* * 31.100 iq. ia./(lb.KmiO. Cdei LTS"
paper, knfc vmppun quality. -50 lb./mm bans ««iht. vmld « 1.000 sq. fe/r-un
Uable
voJltJIM.
CTX ft
0.133S
0.1333
0.034
0.017
067
087
01355
0.034
n i.'n?
O.UG3
.^
•••
1
1
Sources. Perry and Chilton,. Chemical Engineer's Handbook,
McGraw-Hill, 5th Ed., 1973, Ch. 7
-------
acids, strong alkalies, or halogenated chemicals (both organic
and inorganic) because these compounds tend to corrode steel
drums fairly rapidly.
2. Coatings and Linings
Protective coatings and linings are layers of materials that
are impermeable to specific chemical compounds in which they are
applied and are used to prevent or retard significantly the
corrosion of the containers. Useful life is thereby increased.
Coatings are also used for abrasion resistance and to facilitate
cleaning. The same or different coatings may be applied to the
inside and outside of the container.
Coatings and linings are usually applied to containers using
spray equipment followed by curing in baking ovens. The function,
degradation, performance, and types of coatings and linings are
discussed below.
a) Functions. A coating or lining serves two principal
functions: (1) it protects the substrate (metal) from attack by
a corrosive waste? and (2) it prevents the formation of hazardous
products arising from any chemical reaction between waste and
structural material. Sometimes a toxic gas inside the coating is
produced, and the pressure from this gas may, in some instances,
rupture the container or cause bulges. Lined containers are
easier to clean.
The type of waste to be stored may dictate that it is prudent
for an owner or operator to choose a coated container. For example
acidic or chloride-containing wastes should not be stored in steel
3-6
-------
containers unless they are coated. Polyvinyl chloride or
polyester coatings exhibit good resistance to inorganic acids and
alkalies. If organic solvents are to be stored, a coated container
would not be used. Other factors, in addition to the materials
being stored, should be considered in the decision as to whether
to use a lined container. For instance, some coatings, such as
chlorinated rubbers, are degraded by heat and ultraviolet light,
while others, such as epoxies, are degraded by cold temperatures.
b) Degradation. Degradation of a coating is evidenced by
changes in coating color, blistering, and, ultimately, peeling.
c) Performance* The performance of a coating depends upon
its application and is influenced by the following factors:
(1) nature of waste; (2) pH, (3) ambient temperature; (4) storage
conditions e.g. exposure to weatheV; and (5) thickness of the
coating. These factors affect the stability of the coating and,
therefore, its resistance to chemical attack.
One of the most important properties associated with the
chemical resistance of a coating is its permeability. This is an
inherent property determined by the nature of the resin or resins
used, the formulation, the film ^thickness, the nature of the
environment, and the temperature* The extent of permeation is
determined by the actual conditions of use. Some chemicals are
more highly permeating than others. Permeability increases
rapidly with increasing temperature and decreases with increasing
film thickness. Solvation and absorption are other physical
phenomena that can be detrimental to a coating.
-------
d) Types of Coating and Lining
The general characteristics of commonly used industrial
coating of each type of material are categorized in Table 3-2
by the general nature of the binder. It is important to recognize
that differences in manufacturing processes and additives used to
make coatings may result in considerable differences in lifetime
and performance of coatings of the same generic type.
Furthermore, combinations of one or more generic types of
coatings may provide protective systems with a resistance different
and even superior to the separate components. An example is th-3
addition of silicone to alkyds, or vinyls to other types of
coatings to improve not only water and temperature resistance,
but ease of application. Another instance is the copolymerization
of epoxy with phenolics that, makes an air-dry epoxyphenolic with
superior chemical resistance superior to eithfer the phenolic or
epoxy alone.
The most widely used lining materials today are ployethylene,
chlorinated polyethylene, and polypropylene. These materials
have an excellent chemical resistance to strong acids and- strong
alkalies in concentrated and dilute form, but exhibit a poor
resistance to certain organic solvents. They also feature
excellent weatherability and durability.
Phenolics, vinyls, epoxies, and polyesters are among the
many organic coatings applied to metal containers. The following
are some of the most common materials used:
3-3
-------
TABLE 3-2
Properties of Principal Coating Resins
Description
Alkyds Esterification of poly*
hydric alcohol (glycerol)
and a polybasic acid
(phthalic acid), modified
with a drying oil. Hardens
by solvent evaporation
and oxidation
Performance
Good resistance to at-
mosphere weathering
and moderate chemical
fumes: not resistant to
chemical splash and spill-
age. Long oil alkyds have
good penetration although
are slow drying. Short oil
alKyds are fast drying.
Temperature resistant to
225 F.
Limitation*
Mot chemically resistant:
not suitable for appli-
cation over alkaline sur-
faces such as fresh con-
crete.
Comments
Long oil alKyds make ex-
cellent primers for rusted
and pined steel and
wooden surfades. Corro-
sion resistance is ade-
quate (or mild chemical
fumes that predominate in
many industrial areas.
Used as interior and exte-
rior industrial and marine
finishes.
Vinyl* Potyvinyt chloride—poly-
vinyl acetate copolymer
dissolved in strong polar
solvent generally a ke-
tone. Coating hardens by
solvent evaporation.
Chlorinated Formed by adding chic-
rubbers rine to unsaturated. iso-
prene units. Resin is
dissolved in aromatic
hydrocarbons, esters and
ketbnes. Haroens by sol-
vent evaporation.
Insoluble in oils, greases.
aliphatic, hydrocarbons
and alcohols. Resistant to
water and salt solutions.
Not attacked at room tem-
perature by inorganic
acids and alkalis. Fire re-
sistant: good abrasion re-
sistance.
Low moisture permeability
and excellent resistance
to water. Resistant to
strong acids, alkalis.
bleaches, soaps and de-
tergents, mineral oils.
mold and mildew. Good
abrasion resistance.
Strong polar solvents re-
dissolve the vinyl. Initial
adhesion poor. Relatively
low thickness per cost
(1.5-2.0 mils). Some types
will not adhere to bare
steel without primer. Pin-
holes in dried film more
prevalent than other types.
Redissolved in strong sol-
vents. Oegarded by heat
(200 F. dry and 140 F. wet)
and ultraviolet light, but
can be stabi zed to im-
prove these properties.
May be difficult to spray.
especially in hot weather.
Tough and flexible: low
toxicity: tasteless: color-
less: fire resistant. Used in
potable water tanks and
sanitary equipment: widely
used industrial coating.
Fire resistant: 'odorless:
tasteless and non-toxic.
Qu;ck crying and excel-
lent adhesion to concrete
and steel.. Used in con-
crete and masonry paints,
swimming pool coatings.
industrial coatings, marine
finishes.
Eooxv, amine
cured
Epoxy,
polyamide
cured
Epoxy ester
Reaction of active hydro-
gens of aliphatic amines
with epoxy groups of bis-
phenoi-A epicnlorhydrin
resin. Coating hardens by
solvent evaporation and
cures by cross linking.
Amine adduct eooxies
consist of partially pre-
polymerized coatings to
which the remainder of
the amine is added pnor
to application to complete
the cross linking.
Reactive poiyamide resins
(condensation products of
dimerized fatty acids with
polyamines) combined
with epoxide groups in the
epoxy resin. Coating
hardens by solvent evap-
oration but cures by cross
linking.
Formed by reaction be-
tween epoxy resm and un-
saturated fatty acr.ds (com-
monly linseed and soya
oils). Coating hardens by
solvent evaporation and
oxidation.
Excellent resistance to
alkalis, most organic and
inorganic acids, water and
aqueous salt solutions.
Solvent resistance and
resistance to oxidizing
agents is good as long as
not continually wetted.
Amine adducts have
slightly less chemical and
moisture resistance.
Superior to straight epox-
ies for water resistance.
Excellent adhesion, gloss.
hardness impact and abra-
sion resistance. More flex-
ible and tough than amine
epoxies. Chemical resist-
ance slightly less than
straight epoxies. Temper-
ature resistance. 225 F.
dry: 150 F. wet.
Least resistant of epoxy
family. Good weather re-
sistance: cr.emical resist-
ance bener than alkycs
and usually sufficient to
resist normal atmospnenc
corrosive attack.
Harder and less flexible
than other epoxies and
intolerant of moisture dur-
ing application. Coating
will chalk on exposure to
ultraviolet light. Strong
solvents may lift coatings.
Temperature resistance:
225 F. dry. 190 F. wet. Will
not cure below 40 F.;
should be topcoated
within 72 hr. to avoid in-
tercoat delamination.
Maximum properties re-
quire about seven days
cure.
Cross linking does not
occur below 40 F. Maxi-
mum resistances gener-
ally require seven days
cure at 70 F.
Not resistant to strong
chemical fumes, splash or
spillage. Temoerature re-
sistance 225 F dry.
Good chemical and
weather resistance. Best
chemical resistance of
epoxy family. Excellent
adhesion to stesi and
concrete. Widely used in
maintenance coatings and
tank linings.
Easier to apply and too-
coat. more flexible and
Dener moisture resistance
than straight apoxies. Ex-
cellent adhesion over
steel and concrete. A
wioely used industrial and
marine maintenance coat-
ing. Some formulations
can Be aooiied to- wet or
underwater surfaces.
A high quality oil sase
coating, good compatibil-
ity with most other coating
types. Sasy to aooly. Used
widely 'or atmospheric re-
sistance in chemical envi-
ronments on structural
steel, tank exteriors, etc.
-------
TABLE 3-2
Properties of Principal Coating Resins
Epoxy, coal
tar
Silicon*
Zinc rich
Rre
retardarrt
Description
Coal tar mixed with epoxy
mm and cured using ei-
ther an amine or a poiy-
amide. Coating hardens
and cures by cross link-
ing.
Latex resins (generally
styrene-butadiene. poly-
vinyl acetate, acrylic or
Wends) are emulsified in a
water vehicle. After appli-
cation the water evapo-
rates and the resin parti-
cles coalesce and sinter
to form trie coating.
An unsaturated polyester
(resulting from •sterifica-
Uon reaction between
pofynydric alcohol and
polybasic acid) is furtn*'-
reacted with diallyl phtha-
late to cross link and
harden.
Composed of the siioxane
bond with various organic
side chains.
Performance
Excellent resistance to
salt and fresh water immer-
sion. Very good acid and
alkali resistance. Solvent
resistance is good, al-
though immersion in
strong solvents may leech
the coal tar.
Resistant to water, mild
chemical fumes and
weathering. Good alkali
resistance. Latexes are
compatible with most
generic coating types, ei-
ther as an undercoat or
topcoat.
Excellent resistance to
acids, organic solvents
and water, as well as ab-
rasion and abuse resist-
ance.
Inorganic type consists of
zinc dust in binder such
as a silicate. Can be post
or self cure, and can
he/den either by curing
compound, water evapora-
tion or hydrolyzation. Or-
ganic form used vehicles
such as epoxies. phen-
oxies or chlorinated rub-
ber. Hardens by chemical
cross linking or solvent
evaporation.
Ram* retardant use non-
flammable resins and plas-
tieizers with compounds
(sucn as bromates) mat
generate non-flammable
gases, intumescent coat-
ings bubble and swell
upon heating, thus in-
sulating substrate from
the fire.
As heat resistant coating.
requires catalyzation and
baking. With aluminum
pigments can withstand
1.000 P.; with ceramic frits
up to 1.400 F. As a water
repellant resinous sili-
cones in hydrocarbon sol-
vents are used on mas-
onry. Water soluble
alkaline silicone in water
are used on limestone and
concrete.
Resistant to weathering
and mild chemical fume
environments. Zinc in the
coating is attacked when
pH is betow 6 or above
10.5. Inorganic type is
resistant to abrasion and
temperatures up to 700 F.
Can reduce surface flam-
mability or initial heat
effects of fire but should
be used only with conven-
tional fire protection
methods. Properties are
generally better the thicker
the coating.
Limitations
Embrittles on exposure to
cold or ultraviolet light.
Cold weather abrasion re-
sistance is poor. Should
be topcoated within 43 hr.
to avoid intercoat adhe-
sion problems. Will not
cure below 50 F. Black or
dark colors only. Temper-
ature resistance 225 F.
dry, 150 F. wet.
Must be stored above
freezing. Does not pene-
trate chalky surfaces. Ex-
terior weather and chemi-
cal resistance not as good
as solvent or oil base
coatings.
Hard and inflexible. Very
short pot life. Swelled and
softened by strong alkalis.
Minimum thickness of S
mil required fcr cure.
Heat resistant silicones
have moderate cnemicai
Comments
Good water resistance.
Thicknesses to 10 mils per
coat Can 3e applied to
bare steel or concrete
without a primer. Low cost
per unit coverage.
Ease of application and
cleanup. No toxic sol-
vents. Good concrete and
masonry sealers because
breaking film allows pas-
sage of water vapor. Used
as interior and exterior
coatings.
Inert, tile-like appearance.
Good adhesive and cohe-
sive strength. Hign film
build pv coat (10 mils).
Used in maintenance
coatings and linings for
tanks and process equip-
ment
Can be combined with
other coating types to im-
fume resistance- at, lower prove properties such as
temperatures.
Requires clean steel sur-
faces. More difficult to
apply than conventional
coatings. Topcoating may
be difficult especially with
inorganics. Must be top-
coated in severs, corro-
sion environments.
heat and moisture resist-
ance. Water repaiiants are
dear, breathing and dura-
ble. Used as stack coat-
ings and above grade
water repellams.
Eliminates pitting corro-
sion. Despite limitations.
widely used as industrial
and marine primer. In mild
environments can be used
as one coat system.
May not be-as chemically Used to reduce-- name
resistant as same type spread on combustible
non-fire retardant coating, materials and to initially
Generally provide only a insulate structural steel
few minutes delay. Some from heat of fire.
intumescent coatings are
water sensitive and will
not retain full properties
after prolonged exposure
to weather.
Source: K. 3. Tatar, "Engineers Guide to Protective Coatings", Chemical Encineerint
Vol. 79, No. 27, Dec. 4, 1972.
-------
1. Amine—cured epoxy coatings are widely used on tan} 3
and containers. They exhibit excellent resistance to
alkalies, most organic and inorganic acids, water and
aqueous salt solutions, and organic solvents. Their
main disadvantage is that they tend to chalk and
deteriorate with prolonged exposure to ultraviolet
light (i.e., sunlight).
2. Polyamide-cured epoxy coatings are superior to ordinary
epoxies for their water resistance, hardness, impact.and
abrasion resistance, and adhesive strength. Their
chemical resistance is comparable to that of ordinary
epoxies, and their temperature resistance is higher.
3. Epoxy esters are the least resistant of the epoxy
family. However, they have good weather and chemical
resistance and are usually able to resist normal atmos-
pherics corrosive attacks. They are not resistant to strong
chemical fumes.
4. Polyesters are commonly used as maintenance coatings and
linings for tanks and process equipment. They also may
be used to coat steel containers. They exhibit excellent
resistance to acids, organic solvents, water, abrasion,
and improper handling. They tend, however, to swell and
soften in the presence o£ strong alkalies.
In evaluating the compatibility of a coating or lining
material with a specific waste, the permit writer may need to
consult with its manufacturer. The characteristics of the wiste
must, however, be known, particularly pH and concentration of
reactive chemical constituents, before contacting a coating or
lining manufacturer.
Some examples of deterioration of liners by incompatible
wastes include: polyvinyl chloride by strong polar solvents;
chlorinated rubbers by strong solvents; polypropylene, polyethylene
and ABS (acrylonitrile-butadiene-styrene) polymers by benzene,
carbon tetrachloride, or acetone.
4. Specifications
The hazardous waste storage regulations do not include a
3-11
-------
design standard for containers that prescribes strength, corrosion
resistance, and other factors related to the structure of
containers. Such a design standard may, however, be instituted
in the future. Although design standards are not a matter of
regulations, the permit writer is urged to review the corrosion
and compatibility characteristics of proposed waste and container
systems, recommend changes, and make suggestions for improvements.
The Department of Transportation's (DOT) hazardous materials
regulations (49 CFR 173, 178, and 179) require that all hazardous
materials (including waste) be transported in containers that
have been designed according to DOT specifications and have been
approved by DOT. At some future date, EPA may decide to require
that containers used for onsite storage of hazardous waste also
be DOT approved.
Standard DOT specifications for steel drums are given in
Table 3-3. Heavier gauge drums are used to store and transport
liquids, whereas lighter (22- to 26-gauge) steel drums are normally
reserved for handling dry bulk materials. Drums used to store
liquids are generally specified by volume while those used to
store bulk solids are usually specified by dimensions.
Containers certified by DOT as returnable are generally
constructed of 18 or lower gauge metal. Steel drums must also
bear a code indicating the metal gauge, volume capacity,
manufacturer's name, and date of manufacture. In general, drums
that are designed to contain liquids are usually of a closed-head
tyoe, with a 2-inch-pipe-thread opening for filling and emptying,
3-12
-------
TABLE 3-3
TYPICAL STEEL-DRUM SPECIFICATIONS FOR HAZARDOUS MATERIALS
Capacity
gal
55
55
30
Inside
diameter
22 1/2
22 1/2
18 1/4
Inside
height
32 11/16
32 11/16
27 5/16
Outside
diameter
23 27/32
23 27/32
19 19/32
Overall
height
34 13/16
34 13/16
29
Steel
gaug.e,
body
16
8
18
Steel
gauge,
cover
16
16
18
Steel
gauge ,
bottom
16
18
18
Steel
gauge ,
ring
12
12
12
Tare
weight
(approx. )
64.5
55.5
37.5
DOT
spec.
17C
17H
17C «.
17H .
Notes*
1. All dimensions given in inches. Dimensions are within normal manufacturing tolerances of _+ 1/16 in.
(^ 1/8 in. on height).
2. Container weights shown are approximate and may1 vary within the allowable limits Cor manufacturers'
standard gauge.
3. On the 55-gal drumr a third rolling hoop, directly below the top rim, gives strength and rigidity to
meet specifications.
4. These drums meet Department of Transportation Specifications DOT 17H and DOT 17C for storage and
shipment of hazardous materials. They also me'et Rule 40 of the Uni.form Freight Classification, and
Rule 260 of the National Freight Classification. DOT 17H drums also comply with ANSI standards.
5» Table and notes from inland Steel Container Co.
Sources -Schultz, G.A., "In-Plant Handling of Bulk Material in Packages and Containers", Chemical Engine
ing Deskbook, Vol» 85, No. ?4, Oct. 30, 1978.
3-13
-------
and a 3/4-inch-pipe-thread opening for venting. Dry products are
packed in removable head drums. The removable cover is fastened
in place with a locking ring tightened by a bolt or toggle lever.
Variations include a friction plug in the head or bug-type cover
with approximately 20 tabs on the cover that can be bent under
the rim of the drum.3
5. Advantages and Disadvantages
See Table 3-4 for a brief overview of the advantages and
disadvantages of using drums for storage of hazardous waste.
3-14
-------
TABLE 3-4
ADVANTAGES AND DISADVANTAGES OF DIFFERENT
TYPES OF CONTAINERS
ADVANTAGES
DISADVANTAGES
STEEL
1. Versatile - heavy and light-
weight gauges available
2. Widely available
3. Durable
4. Structurally superior to
all other materials
5. Reusable in some cases
6. If lined, highly resistant
to many wastes
3."
If unlined, not for
corrosive wastes
Expensive (coated
drums mere so)
Heavier
PLASTICS
1. Durable
2. Widely available
3- Easy to clean
4. Reusable in some cases
5, For wide range wastes
1. Not for concentrate1
organics
2. Not amendable to ro
handling
V 1ER
1. Light weight
2. Low cost
3.
4.
5.
Only for dry solids
unless coated
Structurally inferi
to steel/plastic
Le-ss durable
Damage by weather
Not reusable _
IOOD BARRELS/
KEGS
1. -Low cost
1. Unlined barrels not
for liquids
2. Damaged by weather
3. Not reusable
BAGS/SACKS
1. Lightweight
2. Low cost
Questionable for hazard
waste storage:
1. Low durability
2. Large volumes bulky
difficult to handle
3. Not for liquids, ig
able, reactive wast
4. Not for handling wi
mechanical equipmer
5. Not reusable
CARBOYS
1- Efficient for small amounts
Glas-s/earthenware not
recommended for hazardc
waste storage:
1. Fragility
2. Not for handling w:
mechanical equipmer
3-15
-------
B. Plastic Containers
1. Compatibility
Plastics are highly resistant to inorganic acids and caustic
materials at various concentrations. They are, however, degraded
relatively rapidly by organic solvents. Polythylene and
polypropylene tolerate dilute organic acids, but are not resistant
to concentrated organic acids.. The chemical resistance of some
important plastics is shown in Table 3-5.
2. Specifications
Plastic containers are manufactured in the same sizes and
capacities as steel containers. Refer to Table 3-3 for these
specifications.
3. Advantages and Disadvantages
See Table 3-4.
C. Fiber Containers
• «^BBBMM*«^^BH-™«^«—•••—H™^»«—^—
Fiber drums are rigid containers commonly used for storing
noncorrosive dry bulk solids. The sidewalls are usually made of
raft piles bonded by an adhesive. The top and bottom ends are
ade of fiberboard or steel, fitted to the cylindrical shell and
apped or latched into place. Sometimes the walls are lined or
aated.
The strength of a fiber drum is directly related to the
umber of plies in the walls. The strength is measured and drums
a'ted by the burst-strength test. Strength rating for the sidewalls
ange from 250 to 900 Ib/in. The bulk capacity of fiber drums
aries from 30 to 400 Ibs. Various construction techniques are
3-15
-------
CHEMICAL RESISTANCE OF IMPORTANT PIASTICS
^ ._
1
1
1
1 . J ....'...
1 '
T ioT »2 so4~
1 50% H2 804
1 10% IIC1
I Acids 10% HN03
1 10% Acetic
i ... . .
1
1 ToTlteOif
I Alkalies 50% NaOH
NH4 OH
NaCl
FeClj
Salts CuS04
NH4 N03 - - - -
Wer \\2~S
JGases Wet C12
Wet'SO^
Gasoline
I Benzene
(Organics CC14
j Acetone
1 Jkl X~-.U-.1 ....
r n
Poly-
propylene
poly-
• 'ethylene
'
1
1
... ......
1
............
1
4
1. ....
4
CAB*
2
4
1
4
2
•7"
4
4.
1
....
1
4
i .
4
1
4
4
4
. A . .
r — p-
i
ABS+IPVC
0
"T"P"
1
l l
2
1
• f
1
. .
1
....
i
. . .
1
4
4
4
. i . .
rr
1
t .
1
1
"T-
2
. \
1
I
4
3
4
. t .
P""T P" "
1 1
Saran (Polyester | ttpoxy
(glass (cjlasn
, L .;„ •___ •_-.!_....
l
T~
3
4. .
1
.... -
-T"
4
2. .
1
3
3
3
. . i . .
r i
2
i
2
1
r 3" ~i
4
1
r™.
2
... i ... . .
j
2
1
4
... i
i
1
1
2
1
1
2
1. .
1
1
.....
-T-
2
. . \ - .
^T"
1
2
2
. . i . .
r - r r — rn
I (Chlori- I
Phenol ic j Fluoro- 1 nated | Poly-
ashestos | carbons | polyether | cartonate
I |Penton (
r i
i
i
3
1
1
1
1
'
. . .
_.' "_^" _- l " " '-"-" " '
r T i
"'T
1
l
2. ...
r~ "~
i
"~r —
i
i
4
... i ....
1 1
1
1
r " n
i
" "
i
j— _n
1
:
i n
i
'. . .
—
i
i „ .
r ;"i
i
.
r-T-- -
3 ;
3
2
... i
r
i
*
r~ *""
i
i
. _„ _
r r
3
4
2
....!....
Ratings are £or long-term exposure at antoient temperatures (<100"F)
1 » Excellent * Cellulose acetate butyrate
2 «» Good •*• Acrylonitrile butadiene styrene polymer
3 » Fair o Polyvinyl chloride, type I
4 « Poor
After Perry and Chilton's,
Chemical • Engineers ^Handbook.
Chemical resistance of Saran-lined pipe
superior to extruded Saran in some
environments
Refers to general-purpose polyesters. Special
polyesters have superior resistance, especially
alkalies.
-------
used for specific bulk-handling and liquid-handling requirements
(Table 3-6).
1. Compatibility
As previously stated, fiber containers are normally used for
solids. If, however, a coating which is liquid resistant is
applied to the inside of a fiber drum, it can be used to store
liquids. Liquid-resistant coatings are commonly made from plastics
such as polyethylene. The compatibilities for plastic-coated
fiber drums would then be determined in the same way as for
plastic containers.
2- Coating and Linings
In order to resist moisture, linings and coatings are often
applied to fiber drums that are to be used to store hygroscopic
material.. In addition, chemical attack or deterioration due to
weather- can be guarded against by a lining that is non-reactive
with the waste or is durable to the climatic conditions.
3. Specifications
In the discussion of specifications for steel containers, it
was noted that containers for shipping purposes must comply with
DOT standards. This is true for any type of containers used to
transport hazardous materials.
DOT fiber drums usually are specified according to inside
diameter, wall thickness, and overall outside height. Wall con-
struction, type of ends and any special barrier treatment are also
directed by DOT. The capacity and construction of s.tandard fiber
drums made in accordance with DOT specifications are listed in
3-18
-------
TABLE 3-6
Materials and Closures of Fiber Drums
Basic construction
All fiber
Fiber sidewalls, wooden heads
Fiber sidewalls, metal heads
Typical top and bottom construction
Wood top and bottom with metal seal
Metal top and bottom
Metal cover with locking bands
Recessed fiber ends
Metal top. and bottom with friction covers
General types of closures
Held by tape
Lever-actuated bands
Crimped lids
Nails
Metal clips
Source: Schultz, G.A., "In-Plant Handling of Bulk Material in
Packages and Containers," Chemical Engineering Deskbook,
Volume 85, No. 24, Oct. 30, 1978.
3-19
-------
Table 3-1.
4. Advantages and Disadvantages
See Table 3-4
D. Barrels and Kegs
Barrels are bilged (bulging) cylindrical containers with
flat heads of equal diameters. Their rated capacity usually
exceeds 30 gallons and their materials of construction may be low-
carbon steel, stainless steel, or a variety of woods, depending
on their use.
They are generally divided into two classes: (1) non-
watertight slack barrels with paper liners to prevent sifting,
which are usually used for dry materials and (2) tight barrels
used to ship liquids.
1. Compatibility
If barrels are made of wood and are unlined, hazardous
liquids should not be stored in them. This is due to the fact
that wood is relatively pervious to most liquids. For the sane
reason, dry materials that must remain dry should not be stored
outdoors in wooden barrels. Barrels and kegs, however, are not
often use for the storage of hazardous waste.
2. Coatings and Linings
Barrels are frequently coated with paraffin in order to make
them watertight. Noncorrosive or mildly corrosive liquids can
then be stored in barrels with such a coating. Other lining
materials, such as blends of wax and polyethylene, also provide
greater resistance to corrosive materials.
3-20
-------
3. Specifications
For barrels constructed of stainless steel, the type of
steel used in the shell and head sheets is identified by an
American Iron and Steel Institute (AISI) type number. The AISI
sets design specifications and standards for iron and steel
storage vessels including tanks and containers. AISI designations
are related in a limited way to DOT specifications; For example,
the type of manufacture of a stainless steel container is shown
by an AISI number, and may be included as a part of the DOT
specifications. The letters HT (heat treatment) following the
steel designation indicate the containers that have been subjected
to stress relieving or heat treatment during manufacture.
Barrels and kegs that are approved by DOT have been constructed
in accordance with standards related to: (1) rated capacity;
(2) composition of materials; (3J construction of container; (4)
dimension of container; (5) closures; (6) markings; and (7) leakage
tests.
S. Bags and Sacks**
Frequently, paper bags are used for packaging pesticides,
and plastic bags are used as liners in rigid containers. Bags
and sacks are also commonly manufactured from transparent films
such as cellophane/ polyethylene, polypropylene, woven paper and
plastic mesh; and from various textiles. Custom paper bags are
also made with special barrier sheets (e.g., foil or polyethylene)
in almost any size desired to meet special requirements. Completely
siftproof and moisture proof construction ara also available. Two
3-21
-------
bag designs are commonly used:
1) Valve design - this has both ends closed during fabri-
cation. The filling is done through a small opening
(valve) in one corner of the bag.
2) Open-mouth design - this has one end closed ^at the
factory. The other end is closed after filling.
Bags and sacks are sometimes used to store hazardous waste.
However, due to their low durability and lack of strength relative
to, for example, steel or plastic containers, the permit writer
should carefully scrutinize the design of any bag or sack pro-
posed for use in storage of hazardous waste as well as the handling
methods proposed. Judgment roust be used to consider the situation
as a whole^
1. Compatibility
Since bags and sacks are manufactured in a wide variety of
materials, a given waste is probably compatible with some type of
bag or sack in most cases. Off-specification chemical products
that become wastes may be stored in their original paper or
plastic packing only if the storage conditions are compatible
with the packing.
It should be noted that plastic bags should be especially
guarded against high ambient tenperatures to prevent rapid
deterioration.
2. Specifications
Table 3-1 gives specifications of standard-size bags in
accordance with the Uniform Freight Classification Committee.
DOT also gives specifications for bags and sacks in 49 CFR 1/8
3-22
-------
F. Carboys
A carboy is a container made of glass, earthenware, plastic
or metal having a capacity of five to thirteen gallons. They are
used principally for carrying corrosive liquids, chemicals,
distilled spirits, and similar materials. Carboys are usually
encased in a rigid protective outer container.6
Glass or earthenware carboys are generally not recommended
for the storage of hazardous waste because they may break. When
faced with a proposal to use carboys, the permit writer is advised
to heed the same cautions as when confronted with a plan to store
hazardous waste in bags or sacks.
1. Compatibility
Generally,, glass carboys may be used to store an off-
specification batch of a substance.
Carboys made of polyethylene are incompatible with wastes
containing benzene, acetone, carbon tetrachloride, or alcohol.
2. Specifications
Carboys designed in accordance with DOT specifications
include the following: (1 name and year of manufacture marked
on the outside of the container; (2) acid-proof stoppers or other
devices, with gaskets securely fastened; (3) venting devices,
when necessary, to prevent internal pressures in excess of 3 psig
at 130F; (4) wooden boxes completely enclosing the body of the
carboy, or wooden boxes completely enclosing the body and neck,
carrying cleats; (5) specified shock tests; and (6) liquid-tight
cap of suitable plastic or other material or liquid-tight cap up
3-23
-------
to the venting pressure when such venting is prescribed.
G. Containers for Storing Ignitable and Combustible Liquids
Ignitable and combustible liquid wastes should 5e stored in
metal containers that meet the requirements of Chapter I, Title 49,
of the Code of Federal Regulations (DOT regulations), or National
Fire Protection Association, NFPA-386, Standards for Portable
Shipping Tanks. In order to comply with these standards/ the
applicant must use containers with one or more devices installed
that have sufficient emergency venting capacity to lunit internal
pressure to 5 psig or 30 percent of the bursting pressure cf the
container, whichever is greater under fire exposure condi-.ions.3
At least one pressure-activated vent having a minimun capacity of
600 cubic feet of free air per hour (14.7 atms and 6 OF ) must be
used. ~It should be set to open at not less than 5 psig. If
fusible vents are used, they should be activated by elements that
operate at a temperature not exceeding 3-0OF When used for
paints, drying oils, and similar materials, where the pressure-
activated vent can become plugged, fusible vents or vents that
soften to failure at a maximum of 300F under fire exposure, may
be used to meet the emergency venting requirement.8
3-24
-------
CHAPTER 4
MANAGEMENT OF CONTAINERS
A. Introduction
This chapter deals with the management of containers and
specific relevant issues that, in most cases, have been addressed
in the regulations. These areas of concern, along with the cited
regulations, are: condition of containers (§264.171); compatibility
of waste with containers (S264.172); incompatible wastes (§264.177);
ignitable or reactive waste (§264.176); and secondary containment
(§264.175).
In addition, container-handling techniques, current storage
practices, facility design considerations and operating procedures,
and information about liners is discussed.
B. Current Storage Practices
As described in Chapter 3, few containers are, in general,
designed specifically for the storage of hazardous waste. Also,
management of hazardous waste storage sites is not a well-developed
art. Therefore, much of the content of this chapter borrows from
functions relevant to storage or various materials in containers
(e.g., warehousing techniques), where extrapolation of good
practices to hazardous waste management is considered desirable.
The applicability of several types of containers to hazardous
waste management was discussed in Chapter 3.
Containers used to store hazardous waste can be efficiently
handled in a few different ways in order to minimize the possibility
of ruptures and leaks and make effective use of space. These methods
4-1
-------
are described below.
Storage practices discussed in this section pertain to both
indoor and outdoor facilities. It should be noted that in addition
to the storage practices where combustible or flammable wastes
are stored, the standards set forth in NFPA 303 for storage of
flammable and combustible liquids should be complied with. These
standards specify requirements for: (1) quantities and freight
limits (2) separation and aisles, (3) building design factors
related to stacking drums, when containers are stored indoors,'and
(4) fire protection.
1. Stacking in Pallets and on Plywood Sheets
Drums, kegs, and pails of various sizes are frequently stored
on pallets. A pallet is a flat, portable platform properly
constructed to sustain loading and handling by mechanical equipment,
A standard pallet dimension is 40 by 45 inches, which allows for
sufficient loading and fits into trailers and freight cars.
Other sizes are also available. Expendable pallets are made of
paperboard or foam plastic and can also be manufactured from foam
blocks glued to a corrugated fiber sheet. Wood pallets are made
from a variety of woods; solid plastic pallets are also available.
The latter have the advantages of not splintering and of requiring
less maintenance. The bearing load of the cheapest pallet is
about 500 Ibs., while the sturdier pallets can carry up to 10,000
Ibs. The Material Handling Association issues specifications for
pallets.
Depending upon the type of container used, the characteristics
4-2
-------
of the waste stored, and the amount of space available, the owner
or operator can place containers in single rows on a pallet or
stack them. For example, if space is tight and containers amenable
to stacking are used, stacking on pallets can be an efficient
usage of space. Another advantage of pallets is that they hold
containers a few inches off the base of the containment area and
may be effective in preventing standing liquids (accumulated
precipitation, leaked or spilled waste, or both) from coming into
direct contact with the containers, thereby accelerating corrosion.
Use of pallets between containers also facilitates later movement
of the containers.
Figure 4-1 illustrates an automatic pallet dispenser. Also
shown are standard loading patterns that make efficient use of
pallet space.
Plywood sheets are also frequently used instead of pallets.
Containers are stacked vertically in order to facilitate handling
and storage.
It is important both for purposes of safety and to prevent
possible rupture or weakening of bottom containers that the
containers not be stacked too high. Factors to consider in
determining the maximum height of a stack include: (1) type
of containers; (2) condition of containers; (3) maximum lift of
fork-lift used to handle the containers; (4) type of fork-truck
attachments available; (5) use of pallets or plywood sheets. All
of. these factors must be judged together in ascertaining a maximum
height for stacked containers or, indeed, whether containers
4-3
-------
FIGURE 4-1
Automatic Container Palletizing
Drum* (S5 gallon) Drums 130 gallon)
L Cotnpact automatic loadw and pallet d«p*n»r
ana pain
b. Standard loading patterns for drums,
and paili makt trfidmT UM of ssao
Source: Perry and Chilton, Chemical Engineer's Handbook, McGraw-Hill, 5th Ed.,
1973, Ch. 7.
-------
should be stacked at all. This is an area where the permit
writer's judgment must be used, giving consideration to the
individual facility and the wastes to be stored. Some containers
may, for example, be too unwieldy to stack. It may not be prudent
to stack drums of highly hazardous waste. Regardless of the type
of container used or the degree of hazard of the waste, containers
of hazardous waste probably should not be stacked very high;
exactly how high is a matter of negotiation between the permit
writer and the permit applicant.
For containers storing ignitable/flammable or combustible
materials, the NFPA standards shown in Table 4—1 should be applied.
Classes IA, tB, and 1C apply to flammable liquids. Classes II
and III apply to combustible liquids. Flammable and combustible
liquids are defined in NFPA 30,8 the Flammable and Combustible
Liquids Code. Stack heights for groups of materials are given.
When two or more classes of materials are stored in the same
stack, the most conservative figure should be observed to maximize
safety.
2. Racks
Usually built of tubular steel, racks are structures on
which containers may be stored either vertically or horizontally.
The racks may be coated with a variety of corrosion-resistant
materials.
Racks can be used to store either a single row of containers
or a double row (see the NFPA publication number 231C, titled
"Rack Storage of Materials").9
4-5
-------
TABLE 4-1
Outdoor Liquid Storage in Containers
Class
1A
IB
1C
II
III
Container ( <60 gal.)
Storage
Max per Pile
Gallons
1,100
2,200
4,400
3,800
22,000
Height
(ft)
10
12
12
12
18
Container (>60 gal.)
Storage
Max per Pile
Gallons
2,200
4,400
8,800
17,600
44,000
Height
(ft)
7
14
14
14
14
Distance
Between
Piles or
Racks
(ft)
5'
5
5
5
5
Source: "Flammable and Combustible Liquids Code, 1981 , National
Fire Protection Association, ANSI/NFPA 30, Boston, MA.
4-6
-------
3. Equipment
Many types of equipment are used in container handling.
This includes fork-lift trucks and front-end loaders equipped
with drum-cradles or drum-grabbers.
4. Aisle Space
Another area of concern in proper drum storage is adequate
aisle space. The owner or operator of a facility must maintain
sufficient aisle space to allow the unobstructed movement of
personnel, fire protection equipment, spill control equipment,
and decontamination equipment to any area of facility operation
in an emergency unless it can be demonstrated to the Regional
Administrator that aisle space is not needed for any of these
purposes (40 CFR 264.35, Subpart C-Preparedness and Prevention).
The exact amount of aisle space, how many aisles and their
placement in the storage area, is another judgment. The amount
of aisle space proposed by the permit applicant must be considered
and its adequacy evaluated based on the facility plan as a whole.
Some guidance as to approximate aisle space can be taken
from NFFPA recommendations. It should be noted, however, that,
with the exception of the specific materials and/or situations
that NFPA is considering in each standard,- the information is to
be considered guidance only and should not necessarily be applied
to storage of other types of hazardous materials. The purpose in
presenting "the NFPA data is to give examples. The NFPA data is
based on separation of materials in order to prevent hazardous
situations, as well as to allow access. NFPA 30s specifies that
4-7
-------
palletized or stacked containers of flammable or combustible
materials should be arranged so that rows of drums are separated
from each other by a minimum aisle of 4 feet. Aisles should be
provided so that no container is more than 12 feet from an aisle.
Where liquids are stored on racks, a minimum 4-foot aisle is to be
provided between adjacent rows or racks and adjacent storage of
liquids. Main aisles should be a minimum of 8 feet wide,.
C. Condition of Containers
The regulation (§264.171) specifies that if a container
holding hazardous waste is not in good condition, or if it begins
to leak, the waste must be transferred to a container that is in
good condition or the waste must be managed in some other way that
complies with the requirements of Part 264.
"Good condition" is a matter of judgment—a container not in
"good condition" would be evidenced by conditions such as severe
rusting, leaks, ruptures, and structural defects (such as excessive
bulges or dents). The permit writer must use his own discretion
in evaluating types of containers and the conditions given by the
permit applicant.
Design of containers is discussed in Chapter 3. The design
affects a container's ability to withstand weathering, handling,
and containerization of wastes for a long period of time. Hence,
design indirectly affects the container condition.
Other factors to consider in assessing a permit applicant's
storage management plan with respect to the potential effect on
the integrity of containers are discussed below.
4-8
-------
1. Climatic Conditions
The physical environment in which containers are stored
affects their durability.
Corrosion resistance and other physical aspects of a container
can be adversely affected by improper storage. For instance,
high humidity may lead to reduced corrosion resistance, particularly
in the case of indoor storage. High temperatures may also
accelerate the corrosion of steel drums.
The ability of a coating to withstand deterioration is also
affected by the environmental conditions of the storage area.
Although many frequently used coatings are resistant to weathering,
problems can develop in cetain situations. For example, some
kinds of chlorinated rubber are degraded by heat, particularly
when wet, and by ultraviolet light. Coal-tar epoxies become brittle
when exposed either to cold or to ultraviolet light. Anine-cured
epoxy coatings, widely used in tanks and containers, deteriorate
upon exposure to light- Containers with any of these types of
coatings should, consequently, not be stored in sunlight.
2. Markings
Containers that have been transported to the facility must
be marked according to DOT regulations. Flammable and combustible
materials may be labelled according to NFPA specifications.
These markings often provide information that may facilitate safe
handling and prevent situations that could lead to premature
failure of the containers.
Markings may be placed on labels or tags or stanciled on drums.
-------
Information such as the type of hazardous waste stored and the
manifest identification number is generally given. Caution
labels, placards, and/or warnings (e.g., ooison, explosives,
corrosives) may be attached as required by- DOT standards.
Flammable liquids may also include the following marking in
accordance with NFPA 30: "FLAMMABLE - KEEP FIRE AWAY."8
Palletized loads of containers require the same mark-ings and
identifications as individual drums.
3. Dating of Containers
A system of dating the age of drums, while not required,
would allow the owner/operator to anticipate when drums may need
to be replaced. Drum dating, coupled with knowledge of the
deteriorative effects of the waste, can provide a more accurate
schedule of drum deterioration and subsequent replacement. The
dates may be marked on the drum or placed on a schematic of the
drum storage area*
4. Steps to Take If a Container Is Not in Good Condition
The permit applicant should have plans for removing containers
from service that are no longer in "good condition." If a
container is leaking, if it is suspected that a failure may be
imminent due to rusting or structural defects, or if it is at the
end of its useful storage life, the contents of the container
should be transferred to a serviceable container. When a leak is
discovered and a suitable replacement drum cannot be found
immediately, it may be acceptable for the leaky container to be
placed in an overpack (a recovered drum that is large enough to hold
4-10
-------
the first container and its contents) . The holes are then filled
with absorbent material.
5. Recovery and Reuse of Containers
Containers constructed of metal are commonly reused, recycled,
or reconditioned. This minimizes disposal of hazardous wastes
and maximizes resources. For a detailed report on container
reconditioning/ consult "Barrel and Drum Reconditioning Industry
Status Profile.*10
If a permit applicant wishes to use reconditioned or recycled
drums, the permit writer should make a careful review to ensure
that the reconditioned, drums will be adequate to contain the waste.
D. Compatibility of Waste with Container (§264.172)
The container and any linings must be compatible with the
waste stored in the container. For a discussion of compatibility
of waste see EPA's manual titled "Compatibility of Wastes in Haz-
ardous Waste Management Facilities."2
E. Incompatible Wastes (§264.177)
The facility standards for handling incompatible wastes
require that (a) incompatible wastes trust not be stored together
in the same container, (b) hazardous waste must not be placed in
an unwashed container that previously held an incompatible waste
or material, and (c) hazardous wastes stored in containers must
be separated from-other incompatible wastes or materials or
protected from them by a dike, herm, wall, or other'device.
The owner or operator can eliminate or at least minimize
mistakes owing to incompatibility by conducting proper waste
4-11
-------
analyses, keeping accurate records, and handling the waste
carefully.
Separate spill and run-off collection sunps are also
advisable in storage areas for incompatible wastes. The wastes
discharged from collection sumps should be segregated from other
wastes that are incompatible. Site or floor plans of the facility
or piping and instrumentation diagrams (P&IDs) showing location
of collection sunps should be furnished by the facility owner or
operator.
F- Storage of Ignitable or Reactive Waste (§264.176)
Containers of ignitable or reactive wastes must be located
at least 15 meters (50 ft.) from the facility property line.
Facility owners or operators should also take precautions to
prevent accidental ignition or reaction of these wastes by
separating and protecting them from open flames, smoking, cutting
and welding, contact with hot surfaces, frictional heat, spontaneous
ignition sources (e.g., from heat-producing chemical reactions),
and radiant heat. NFPA standards for flammable and combustible
materials shoud be applied when storing ignitable or reactive waste.
G. Containment (§264.175)
In storage areas where a secondary containment system is
required, the system must be sufficiently impervious that it
will hold collected material until detection and removal. The
containment system must also drain efficiently so that standing
liquid will not remain on the base for extended periods of time
subsequent to leakage or precipitation, and containers mist be
protected from accumulated liquids. The containment systam must
4-12
-------
be large enough to hold 10 percent of the volume of the containers
or the volume of the largest containers, whichever is greater.
Run-on must be prevented unless the containment system is large
enough to accommodate it, and collected material must be removed
from the collection area as soon as necessary in order to prevent
overflow.
Storage areas that store containers holding only wastes that
do not contain free liquids are not required to have a secondary
containment system, provided that (1) the storage araa is sloped or
is otherwise designed and operated to drain and remove liquid
resulting from precipitation or (2) the containers are elevated
or are otherwise protected from contact with accumulated liquid
(J254.t75(O).
Some of the general factors to be considered in designing
and evaluating a containment system are discussed below:
1. Properties of the Waste Stored
Some consideration should be given to compatibility of the
type of wastes stored with the liner or base to be used. For
example, if highly corrosive wastes are to be stored, a very
durable, corrosion-resistant base should be installed.
2. Number of Containers
The maximum number of containers, volume of waste, stack
height, aisle space, and size of the storage aree within the
containment area should be considered.
3. Container Capacity
The secondary containment system must be designed to allow
4-13
-------
for accumulation of precipitation. Storm intensity in the araa
where the facility is located should be used to determine maximum
precipitation. The flow velocity in the drainage system (i.e.,
drainage channel or pipe) and the bottom and side slopes of the
containment structure must also be considered. The design
specifications of the facility will indicate if the capacity of
the containment system will equal or exceed 10 percent of the
total capacity of the containers in the drainage area.
Storm frequency and intensity (expressed in inches) data for
a given area are published by the U.S. National Weather Service.
Data can also be obtained from the National Climatic Center in
Ashville, North Carolina. Run-off volume is commonly calculated
as a fraction of rainfall, which is known as the run-off coefficient,
Capacity of the containment system can be calculated from these
sources. (Refer to the Soil Conservation Service handbook for a
detailed discussion of these calculations.)11
The storage area should be graded in a manner to divert
spills away from buildings or other enclosures or should be
surrounded by a curb to contain spills. When curbs are used,
provisions must be made for draining accumulated ground or rain
water, or spills of liquids. Drains must discharge at a safe
location and be accessible to operation under fire conditions.
4. Adequacy of the Containment System
Section 264.175 requires that the containment system Dase
must be "free of cracks or gaps and . . . sufficiently impervious
-------
to contain leaks, spills, and accumulated rainfall until the
collected material is detected and removed." since no -material
is totally impervious, the permit writer must determine if the
material proposed for the base by the permit applicant is adequate
to hold waste or precipitation until it can be detected and removed.
Waste migration through a base or liner material can be
calculated based on the permeability of the base material and the
hydraulic impact load of the waste. formulas and a detailed
discussion of how to perform the calculation can be found in EPA's
manual on Landfill and Surface Impoundment Performance Evaluation. *2
If the permit vvriter can be assured that the base of the
containment system will be dry most of the time, there would be a
negligible hydraulic impact load on the base and, therefore,
minimal waste migration through the base. If all of the other
standards for containers in Subpart I are met, the base should
remain dry most of the time. For example, if the permit applicant
provides a design showing that (a) spilled or leaked waste or
precipitation will remain on the base for short periods only (i.e.,
because the base is sloped to provide drainage or accumulated
liquids are pumped out of the containment area shortly after
being detected); (b) that waste will not contaminate the outside
of the containers and, therefore, generate leachate after precip-
itation; or (c) that the storage area will be inspected weekly
and that the inspector will be able to visually assess the condition
of all containers and that any spills or leaks will be quickly
4-15
-------
cleaned up, then the thickness of the base should not be dependent
on waste migration.. It should, rather, be based on the ability
of the base to adequately support the weight of the drums. In
order to make this type of assessment, the permit application
should provide the permit writer with the engineering data used
to contruet the base.
The permit writer may decide, however, that other storage
management plans or designs in which accumulated liquids would
remain on the base for longer periods of time, or in which it
might not be possible to closely monitor each container, might
be acceptable- In these cases, the permit applicant must
demonstrate that the waste will be contained by the base for the
life of the facility. ,To do this, the permit applicant needs to
submit calculations showing time for waste to leak through tne
base, as mentioned previously-
5. Auxiliary structures
The design o'f the containment system may include curbs or
dikes surrounding the storage area and in areas between incompatible
wastes. Curbs or dikes may, in some cases, be an integral part
of the design for containment capacity and is one means of
preventing run-on. Ditches or trenches surrounding the perimeter
of the storage area may also be used to prevent run-on.
The Subpart I regulations do not require that these barriers
be impervious to the waste being stored; however, the permit
writer will probably want to be assured that they have been
constructed of a reaonably impermeable material. Curbs may
4-16
-------
or the storage area may also be used to prevent run-on.
The Subpart I regulations do hot require that these barriers
be impervious to the waste being stored; however, the permit
writer will probably want to be assured that they have been
constructed of a reaonab-ly impermeable material. Curbs may
typically be made of concrete and are sometimes coated with an
impermeable material such as epoxy. Berms and ditches may be
lined with a synthetic membrance or may be made of a natural
liner material such as clay. (For more information on liners see
Lining of Waste Impoundment and Disposal Facilties.13)
Generally, however, materials such as concrete and asphalt
are utilized in storage areas for containers. Liners may be used
in placed of, or in addition to, concrete and asphalt.
The height of curbs, walls, or dikes is important not only
for containment of spilled or leaked waste and accumulated
precipitation, but in the prevention of run-on into the storage
area. Run-on can be diverted by proper grading. In evaluating
the height and capacity of the containment structure, the permit
writer should take into consideration storm intensity and frequency
data in the area of the facility and capacity of the leachate
and run-off collection system. If a containment system is not
capable of adequately discharging run-off from the containment
area during a severe storm, the containment structure must provide
sufficient holding capacity to prevent overflow. In addition,
the containment system design should allow for a reasonable
safety factor beyond the minimum height of the barrier.
4-17
-------
These include drains that lead into a sump under the base; a
sloped base that directs liquids into a sump; elevation of
containers on pallets or racks and a plan to pump accumulated
liquids out of the storage area; and a roof over the container
area. The last design, it should be noted, would only protect
against contact of containers with precipitation. Discharged
waste would have to be removed in some other manner.
Where a drainage sump is provided, the permit writer should
ascertain if the sump, pump, and discharge piping are of sufficient
capacity and if the materials of construction are compatible with
the wastewater. The permit applicant should provide sump, pump,
and piping specifications and diagrams for review.
7. Ability to Clean Up and Remove Spills
The permit writer must be assured that the facility owner or
operator has adequate plans and equipment for cleaning up and/or
removing any spilled or leaked waste in the containment area. A
contingency plan should be included in the permit application for
this purpose.
4-18
-------
CHAPTER 5
INSPECTIONS OF CONTAINER FACILITIES
Regular inspections of container storage areas is a major
management tool for preventing discharge of hazardous waste into
the environment. The regulations require that containers, container
storage areas, and containment systems be inspected weekly (§264.174)
In a container storage area/ inspections can only be expected
to reveal obvious problems and give the facility owner or operator
a general idea of the type and rate of long-term deterioration of
containers. Because corrosion inside a container cannot be
detected by visual inspection of a container (external corrosion
would be evident) and because sudden or accidental damages
occur (e.g., ruptures or leaks), the facility owner or operator
should expect to find failures when he make inspections.
Inspections must, of course, be combined with remedial action.
The permit writer should review the inspection plan as well as
proposed emergency measures in the permit application.
Ihis chapter discusses inspection techniques and evaluation
of inspection plans.
A. Containers
Corrosion of metal containers is the major cause of leaks
at container storage facilities. To some degree, corrosion of
metal is a natural phenomenon. With time, all metals corrode to
a certain extent. Since it is an aging process, the management
of the site should be planned with the idea that containers
susceptible to corrosion will deteriorate over time and, hence,
5-1
-------
require replacement.
Corrosion may be accelerated when corrosive wastes are stored
or when containers are exposed to weather conditions. (See
Chapter 4 for a discussion of the impact of climatic conditions
on containers.)
The information presented in this chapter should be regarded
as a general overview of the subject of corrosion. The permit
writer should refer to the guidance manual on hazardous wastes
compatibility2 for more information on corrosion.
A visual maintenance check is the simplest way to detect
any corroded, leaking, or structurally defective containers.
Since corroded or deteriorating containers will eventually lead
to leakage, the detection and packing of faulty containers is
integral to spill and" leak prevention.
Various forms of corrosion produce different visual results.
Some of these corrosion types and signs to be alert for are
outlined below.
1. Forms of Corrosion14
Corrosion is most often confined to the metal surface of a
container. The complete corrosion reaction is divided into an
anodic portion and a cathodic portion, occurring simultaneously
at discrete points on metallic surfaces. Local cells created
either on a single metallic surface (because of local point-to-
point differences on the surface) or between dissimilar metals
may generate the flow of electricity from the anodic to the
cathodic areas. Bimetallic cells derive their driving voltage
5-2
-------
from the interaction of two different metals. Bimetallic cells
are created by the connection of two dissimilar metals.
Corrosion may be uniform or localized. Its product may be
easily recognizable, as the reddish-brown particles in the case of
iron oxide. The various forms of corrosion are identified below
and are illustrated in Figure 5-1.
• Uniform Corrosion, aniform attack over large areas is
the most common form of corrosion. Proper selection of
containers and linings or coatings can significantly
reduce corrosive action. If corrosion causes discoloration
in a particular case, uniform corrosion may be more easily
spotted than localized attacks on metal containers.
0 Crevice Corrosion. Various changes in the area surrounding
the crevices of a container (usually at the seams), such
as a deficiency of oxygen or changes in acidity, may cause
corrosion* Corrosion also commonly occurs in crevices
that contain, for example, dirt deposits, corrosion
products,, or scratches in the paint film. Consequently,
particular attention should be paid to seams when
inspections are carried out.
0 pitting Corrosion. Pitting corrosion is caused by the
formation of holes in an otherwise relatively unattacked
surface. The holes can have various shapes, with the
shape often being responsible for continued corrosion.
Pitting is generally a slow process (taking several months
or years to become visible). The small size of a pit and
the small amount of metal dissolved make detection
difficult in the early stages. Selection of containers
known to be resistant to pitting in .a given environment
is usually the best protection against this problem.
0 Exfoliation and Selective Leaching. Exfoliation is
corrosion that spreads below the surface. It differs
from pitting in that the attack has a laminated appearance.
Whole layers of material are eaten away and the attack is
usually marked by a flaky and sometimes blistered surface.
Exfoliation and selective leaching occur mostly on steel-
aluminum alloys. Consequently,' special attention should
be given to container bottoms.
a Intergranular Corrosion. In a severe case of intergranular
corrosion, the surface of the metal container will appear
5-3
-------
FIGURE 5-1
TTPSS OF CORROSION
LOCALIZED corrosion is more aifficuit to control man uniform attack
Source: M. Hawthorne, "Understanding Corrosion", Ch^lca! Engineering, Vol. 79,
No. 27, Dec- 4, 1972.
-------
rough and feel "sugary."
0 Stress-corrosion Cracking. Stress-corrosion cracking is
often identified by the presence of crack branching.
A metal container that fails because of stress-corrosion
cracking will usually have visible corrosion products on
the fracture surface. Stacking containers may exacerbate
this form of corrosion. Therefore visual inspection
should include checking of stack heights.
* Galvanic Corrosion. Galvanic corrosion is the excess
corrosion rate that is associated with electrons flowing
from an anode to a cathode in the same environment.
Galvanic corrosion is an important consequence of" coupling
two metals widely separated in the galvanic series. The
result is an accelerated attack on the more active metal.
Therefore visual inspection should include the checking
of the types of containers stored next to each other, as
well as how they are stored.
Where corrosion or defects are anticipated and visual inspec-
tion confirms the expectation, the contents must be transferred to
a container that is in good condition.
Although inspections of containers are required weekly, under
some circumstances certain containers should be inspected more.
frequently. Reasons for additional inspections include: results
of previous inspections, contraction and potential for corrosion
of the container, properties and corrosion rates of the wastes,
potential risk of air or water pollution, and safety to personnel.
In addition, containers holding new wastes that have not previously
been stored at the facility may warrant more frequent inspections
until adequate data on the containers performance have been
collected.
B. Container Storage Areas and the Containment System
1. Visual Inspection
Curbs or dikes can be examined for deterioration and container;
5-5
-------
can be moved from the base periodically in order to detect any
cracks or holes in the-base. (Moving the containers probably
provides a better than usual inspection of the drums as well.)
Vegetation surrounding dikes should be examined for any changes
that may be caused by leachate or overflew of spilled waste; a
change might be either more luxuriant growth or dying vegetation.
Further/ the base should be checked to see that containers are
not standing in liquids or, if the containment design includes a
sloped base or drains, that liquids appear to run off or drain
properly. Subsequent to a rainfall, leakage, or spillage, systems
designed to remove liquids should be examined to determine if
they are functioning properly. Drains should be checked, for
example, to see that they are not clogged.
2, Testing
Auxiliary features such as drainage systems, simps, and pumps
should be tested periodically. Emergency response equipment such
as alarms and communication systems should also be tested.
As with containers, certain situations or conditions may
warrant more frequent inspection of some areas. Situations where
drums are subject to the elements, such as outdoor storage, and
sections of the containment area that are deteriorating more
rapidly than other parts may justify more frequent inspections.
C. Evaluation of an Inspection Plan
An inspection plan should be comprised of a checklist of
equipment and items to be inspected, directions for the method of
inspection, and a separate schedule for those areas to be inspected
5-6
-------
more frequently than specified in the regulations. Unlike the design
evaluation of a facility, whi-ch tends to be conceptual, the
inspection evaluation is necessary to make certain that the
owner/operator performs all mechanical, visual, or other routine
or special inspections. As long as the containers are inspected
and judged to be in good condition, the inspection plan may be
viewed as satisfactory. The inspection plan should specifically
note that the owner/operator is responsible for the detection of
corrosion, cracks, leaks, bulges, buckles, and other signs of
deterioration. The inspection plan should also indicate that che
owner/operator will use industrially acceptable practices to
locate any faulty items and make necessary repairs as soon as
possible. Remedial procedures for faulty containers, spills, and
leaks should be induced in the plan. The plan may also provide
for changes in operational procedures to ensure the safe operation
of the facility.
The evaluation of an inspection plan should include a review
of employees qualifications to conduct inspections, procedures
for responding to improper operations observed during inspections,
recordkeeping procedures, the inspection log, and personnel
training plan. Some key items to be inspected are listed in
Table 5-1.
5-7
-------
TABLE 5-1
CONTAINER STORAGE FACILITY INSPECTION POINTS
I. Containers
1. corrosion, leakage, or structural defects
2. proper placement
3. proper stacking (including required aisle space)
4. segregation of incompatible wastes
5. missing or improper labeling
6. properly closed containers
II. Container Storage Area and Containment System
1. base for lacerations, cracks
2. berms/dikes for cracks, structural stability, freeboard
3. collection sump and pumping systems for proper operation,
periodic maintenance (visual and physical tests)
4. emergency response equipment for alarms, communication
systems, fire fighting capabilities
5. fences or barriers for controlling access to the facility
6. clean-up procedures for debris and refuse
7. personnel safety precautions
8. surrounding vegetation for changes
9. base drainage system, if used (visual and physical tests)
5-8
-------
CHAPTER 6
HAZARDOUS WASTE CONTAINER COSTS
Data presented on costs of operating a container facility is
provided in this manual purely for informational purposes. The
permit writer is not required to evaluate a permit applicant's
costs for maintaining a container storage facility* However, he
should be cognizant of the economics of options available to the
permit applicant. The costs provided here are brief, general, and
are not meant to substitute for current market figures. They
should not be used for engineering design.
A. Introduction
The cost of constructing and operating a container storage
area can be broken down into three main components:
(1) cost of the containers,
(2) cost of constructing the containment system, and
(3) operating cost.
Operating costs will not be addressed in this chapter,
because it is dependent on site-specific factors such as frequency
of moving or emptying containers.
B. Container Costs
The most widely used type of container is the 55-gallon
steel drum. Table 6—1 presents the prices of new 55-gallon drums
obtained from the Bureau of Census report "Steel Shipping Drums
and Paints" (also known as the M 34K report).13 Table 6-2 presents
cost data on steel drums obtained in a survey by the .National
Barrel and Drum Association.
6-1
-------
TABLE 6-1
PRICES OF NEW CONTAINERS
(Bureau of the Census Survey)
PRICE (in dollars)
March March
1980 1979
Tight Head
18-gauge and heavier 18.07 17.26
19- and 20-gauge** 18.39 16.86
Open Head
18-gauge and heavier 22.37 19.33
19- and 20-gauge** 16.82 15.60
* Container price is at the point of production. It includes the
net sales price, f.o.b. plant, after discounts and allowances,
exclusive of freight charges and excise taxes.
** Includes 20/18 gauge containers
Source: "Steel Shipping Drum and Paints," Report M34K, Bureau of
Census.
TABLE 6-2
PRICES OF NEW AND RECONDITIONED DRUMS
(NAB ADA survey)
Mean Standard Range
Drum Type Price ($) Deviation Min. Max.
New Tight Head 17.47 2.66 13.50 27.00
New Open Head 19.42 4.31 15.00 34.00
Reconditioned Tight Head 11.74 1.33 9.00 15.19
Reconditioned Open Head 11.89 1.79 9.75 15.50
Laundry/Service Fee 5.78 1.18 4.00 9.80
source. - Survev conducted by National Barrel and Drum -Association
Source. ™*v**™". -Srrel and Drum Reconditioning: Industry
Status Profile," Solid and Hazardous Waste Research
Division, Municipal Environmental Sesearch Laboratory
Cincinnati, Ohio.10
6-2
-------
Costs may be substantially higher for other types of con-
tainers and vary widely with size. The cost of a painted steel
(liquidexpansion) container ranges from $58 for an 8-gallon
container to $120 for a 40-gallon container. Steel ASME expansion
(painted) containers range from $240 for an 18-gallon container
to $1,925 for a 515-gallon container.
C. Containment System Costs16
The cost of a typical containment system for a container
storage area can be subdivided into three major cost components:
(1) base,
(2) curb or' dike, and
(3) sump pump.
T.he estimating costs for model containment systems designed
for the storage of 100, 200, and 500 55-gallon drums are presented
below. The major assumptions in estimating these costs have been:
(1) containers (2 1/2 diameter x 4' height) are stacked
in two tiers;
(2) no special foundation design (e.g., use of pilings)
was necessary; and
(3) the base is surrounded by 6-inch curbs and drains to a
sump pump.
1. Area of Containment System
a. 100 containers (stacked 7 in 7 rows, 2 tiers high)
3 ft./container
» 450 sq.; ft. (211 x 21')
+ 50% for access and drainage
* 1000 sq. ft. (32' x 32' )
Area * 111 sq. yds.
6-3
-------
Perimeter * 42 yds.
b. 200 containers (stacked 10 in 10 rows, 2 tiers high)
= 900 sq. ft. (301 x 30')
+ 50% for access and drainage
- 2025 sq. ft. (45' x 45')
Area » 225 sq. yds.
Perimeter » 60 .yds.
c. 50 containers (stacked 16 in 16 rows, 2 tiers high)
3 ft. container
- 2250 sq. ft. (471 x 47')
+ 50% for access and drainage
» 5000 sq^ ft. (71- x 71')
Area » 556 sq. yds.
Perimeter » 94 yds.
2. Cost Estimates
Number of Containers
100 200 500
Base - $10/sq. yd. $1,110 $2,250 $5,560
Curb - $ll/yd.* 462 660 1,034
Pump » $2,000* 2,000 2,000 2.,000
Total $3,572 $4,910 S8,594
Cost per container 536 $25 $17
Annualized cost over
a 20-year period $219 $300 $=26
(aanualization factor » .0612)
6-4
-------
These storage areas can be compared by utilizing the following
tables
Number Storage Total Cost per Annualized
of Containers Space (ft.2) Space (ft.2) container cost
100
200
500
450
900
2250
1000
2025
5000
S36
25
17
219
300
526
Obviously, other container arrangements are possible and may
be acceptable to the permit writer. In every case cost, estimates
should be obtained for the specific facility in question, utilizing
up-to-date data.
6-5
-------
REFERENCES
1. Administrative Procedures for Obtaining RCRA Permits (Washington,
D.C.: U.S. EPA), SW-934.
2. Theodore P. Senger and Fred C. Hart Associates, Inc. ,
Compatibility of Wastes in Hazardous Waste Management Facilities
(Washington, D. C.: U.S. EPA, Office of Solid Waste, July 1981).
3. John H. Perry and Cecil H. Clilton, Chemical Engineers' Handbook,
5th ed», (New York: McGraw Hill 1973).
4. R.B. Tator, "Engineer Guide to Protective Coatings," Chemical
Engineering, (79) 27, 1972.
5. G.A. Schult~, "In-plant Handling of Bulk Material in Packing
and Containers," ibid. (85) 24, 1978.
6. J. F. Hanlon, Packaging- Marketplace, (Detroit, Mich.: Gale
Research Co., 1978).
7, National Fire Protection Association, "Standards for Portable
Shipping Tanks NFPA 385," 1979.
8. National Fire Protection Association, "Flammable and Combustible
Liquids Code NFPA 30 1981.
9. National Fire Protection Association, "Rack Storage of Materials
NFPA 231," 1980.
10. J. Touhill, "Barrel and Drum Reconditioning: Industry Status.
Profile," EPA Solid and Hazardous Waste Research Division
(Cincinnati, Ohio: Municipal and Environmental Research
Laboratory, 1980).
11. Soil Conservation Service, SCS National Engineering Hydrology,
(Washington, D.C.: U.S. Department of Agriculture, 1972).
12 Charles Moore, Landfill, and Surface Impoundment Performance
Evaluation, (Washington D.C.: Office of Solid Waste, U.S. EPA,
1980) .
13. Matrecon, Lining of Waste Impoundment and Disposal Facilities,
U.S. EPA Washington, D.C.: Office of Solid Waste, U.S.. EPA, 1980)
14. M. Hawthone, •rrnrioT-sf.andina Corrosion," Chemical Engineering,
(79) 27, 1972.
15. "Steel Shipping Drums and Paints," Report M34K, Bureau of Census.
16. Pope-Seid Associates, St. Paul, Minnesota. Prepared under EPA
Contract No. 68-01-6322.
7-1
------- |